JUDGMENT :

R.Narayana Pisharadi, J

The appellants/assessees are Co-operative Societies registered under the Kerala Co-operative Societies Act, 1969. The issue raised in these appeals relates to their claim for deduction under Section 80P(2) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act').

2. The claim for deduction under Section 80P (2) of the Act made by the appellants was denied by the Assessing Officer by treating them as Co-operative Banks and not as Primary Agricultural Credit Societies. Aggrieved by the assessment orders thus passed by the Assessing Officer, the appellants filed appeals before the Commissioner of Income Tax (Appeals). The appellate authority, by following the judgment of this Court in Chirakkal Service Co-operative Bank Limited v. Commissioner of Income Tax : 2016 (2) KHC 726: 2016 (2) KLT 535, allowed the appeals and directed the Assessing Officer to grant deduction under Section 80P (2) of the Act, on the ground that the assessees are classified as Primary Agricultural Credit Societies by the Registrar of Co-operative Societies.

3. The revenue challenged the orders passed by the first appellate authority in second appeals filed before the Inc